STIPULATION AND [PROPOSED] ORDER

(Iowa District Court – General Civil Matters)

[// GUIDANCE: Provide sufficient factual support for good cause. For modifications of trial or discovery deadlines, cite the existing Scheduling Order and explain why the extension will not prejudice trial settings.]

1. CAPTION

text
[ATTORNEY OR SELF-REPRESENTED PARTY]
Name: [NAME] (AT No. [NUMBER])
Firm: [LAW FIRM NAME]
Address: [STREET ADDRESS]
City, State ZIP: [CITY], Iowa [ZIP]
Telephone: [TEL] | Facsimile: [FAX]
E-Mail: [EMAIL]

Attorney for [PARTY NAME]

IN THE IOWA DISTRICT COURT FOR [COUNTY] COUNTY

[PLAINTIFF NAME],
Plaintiff,

v. Case No. [CASE NUMBER]

[DEFENDANT NAME],
Defendant.

2. STIPULATION

The Parties stipulate and agree as follows:

1. Background.
   - The Court entered a Scheduling Order on [DATE].
   - [Identify upcoming deadlines or hearings affected].

2. Agreed Terms.
   a. [TERM 1: e.g., “Discovery shall be completed by [DATE], extending the current deadline by [NUMBER] days.”]
   b. [TERM 2: e.g., “Expert witness disclosures pursuant to Iowa R. Civ. P. 1.500(3) shall be served by [DATE].”]
   c. [TERM 3: e.g., “The final pretrial conference currently set for [DATE] is continued to [DATE], or such other date set by the Court.”]
   d. [Additional terms as needed].

3. Authority. This stipulation is made pursuant to Iowa R. Civ. P. 1.431 and the Court’s Scheduling Order ¶ [NUMBER], and is supported by good cause because [JUSTIFICATION].

4. Reservation. All other provisions of the Scheduling Order remain in effect.

5. Request for Order. The Parties jointly request that the Court approve the stipulation and enter the proposed order below.

3. SIGNATURES

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DATED: ______

[LAW FIRM NAME]
By: ________
[ATTORNEY NAME]
AT No. [NUMBER]
Attorney for [PLAINTIFF]

[SECOND LAW FIRM NAME]
By: ________
[ATTORNEY NAME]
AT No. [NUMBER]
Attorney for [DEFENDANT]

[// GUIDANCE: Include additional counsel signatures. Electronic signatures “/s/ Name” are acceptable via EDMS.]

4. [PROPOSED] ORDER

text
Upon consideration of the Parties’ Stipulation and for good cause shown, IT IS ORDERED:

1. The Stipulation is APPROVED and incorporated herein.
2. [ORDERED TERM 1].
3. [ORDERED TERM 2].
4. [ORDERED TERM 3 / ADDITIONAL RELIEF].

All other deadlines set forth in the Scheduling Order dated [DATE] remain unchanged.

SO ORDERED this _ day of _____, 20__.

District Court Judge
[// GUIDANCE: Insert the judge’s typed name below the signature if requested.]

5. CERTIFICATE OF SERVICE

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I certify that on [DATE], I electronically filed the foregoing using EDMS, which will serve all registered parties. Copies were served by [MAIL / EMAIL] on any parties not participating in EDMS:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
AT No. [NUMBER]
[// GUIDANCE: Confirm service complies with Iowa R. Civ. P. 1.442 and 1.442(4).]

6. FILING & SERVICE CHECKLIST

• Identify Iowa authority. Reference Iowa R. Civ. P. 1.443, 1.607, 1.910, or other rules supporting the stipulation, and check for county-level scheduling orders that may control.
• Use EDMS properly. File the stipulation and proposed order under the correct filing type, upload exhibits as separate attachments when necessary, and provide an editable order if the judge requires one.
• Serve outside EDMS. Send paper or email copies to any party not participating in EDMS, documenting compliance with Iowa R. Civ. P. 1.442.